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REACH-IT

Invoicing and Payments

Who sets ECHA's fees?

ECHA fees and charges payable under Regulation (EC) No 1907/2006 ('the REACH Regulation') are set by the European Commission, with the agreement of the EU Member States. They are laid down in the Commission Regulation (EC) No 340/2008 of 16 April 2008 on the fees and charges payable to the European Chemicals Agency (OJ L 107, 17.4.2008, p. 6, "the REACH Fee Regulation"), as subsequently amended by the Commission Implementing Regulation (EU) No 254/2013 of 20 March 2013 (OJ L 79, 21.3.2013, p. 7) and by the Commission Implementing Regulation (EU) 2015/864 of 4 June 2015, and are subject to regular reviews.

For more information, please consult the European Commission website: http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02008R0340-20150625

What will the amount of the invoice be?

Fee amounts are specified in the Commission Implementing Regulation (EU) No 2015/864 of 4 June 2015 amending Regulation (EC) No 340/2008 on the fees and charges payable to the European Chemicals Agency ("the REACH Fee Regulation").

Information related to the chargeable confidentiality claims can be found in chapter 3.5 of the manual “Dissemination and Confidentiality under the REACH Regulation” at: https://echa.europa.eu/manuals.

ECHA encourages to run the Fee calculator plugin before submitting the IUCLID dossier in REACH-IT. A potential fee mismatch will enable you to identify and correct a mistake in your dossier before the submission.

Fee Calculator Plugin

How will I receive ECHA's invoice?
After your REACH submission has been received by ECHA, you will receive an electronic invoice only, via REACH-IT. This electronic invoice can be downloaded from your REACH-IT account in PDF format.
When do I have to pay ECHA's invoice?

The timelines for payment of fees levied under the REACH Regulation are specified in the REACH Fee Regulation as subsequently amended by the Commission Implementing Regulation (EU) No 2015/864 (see QA 716) and the precise due date is set out in ECHA's invoice.

Fees invoiced for initial and update registrations

In the case of fees for registrations submitted, as well as in the case of updates of a registration, the initial payment due date of the fee is set at 14 calendar days from the date on which the invoice was notified to you. However, in the case of fees for registration of pre-registered substances, which are submitted to ECHA during the two months preceding the relevant registration deadline specified in Article 23 of the REACH Regulation, the initial payment due date of the fee is set at 30 calendar days from the date on which the invoice was notified to you.

If the payment has not been made within the prescribed period (by the initial payment due date), ECHA will set a second deadline for payment. This second deadline (extended due date) is usually up to 60 calendar days from the initial payment due date.

If the payment is not made by the extended payment due date, the registration fails the completeness check and will be rejected.

For updates of a registration unrelated to tonnage band changes, the registrant has the possibility to request a further extension of the second deadline for payment of the corresponding fee before its expiry. In practice, this request for extension of the second deadline for payment applies only to:

  • Fees levied for new chargeable confidentiality claims included in spontaneous updates;
  • Fees levied as a consequence of a legal entity change.

The request for extension should be submitted before the expiry of the second deadline via the ECHA Helpdesk using the contact form on ECHA's website.

If the payment is not made by the deadline of the extension, the update fails the completeness check and will be rejected.

Fees invoiced for notification of an exemption for product and process oriented research and development (PPORD), as well as charges for requests to extend this exemption.

Fees for notification of PPORD exemptions: the initial payment due date of the fee is 7 calendar days from the date on which the invoice was notified to you. Requests to extend a PPORD exemption: the initial payment due date of the fee is set at 30 calendar days from the date on which the invoice was notified to you.

If the payment has not been made within the prescribed period (by the initial payment due date), ECHA will set a second deadline. This second deadline (extended payment due date) is usually up to 60 calendar days from the initial payment due date.

Where the payment is not made by the expiry of the second deadline, the notification or the request for an extension will be rejected.

How do I pay ECHA's invoice?

Bank transfer is the only accepted payment method. Other types of payment, such as cheque, banker's draft or cash, are not accepted by ECHA.

Payments should be executed in Euros only and it must be ensured that the full amount of the invoice is received by ECHA. Deductions of bank charges, from exchange rate differences or of any other costs will lead to an underpayment of the invoice.

The following bank details are indicated on all invoices issued under the REACH Regulation:

Bank: OP Corporate Bank plc, Gebhardinaukio 1, 00510 Helsinki, Finland

Account number: 500001-20243349

IBAN Code FI98 5000 0120 2433 49

BIC/SWIFT code: OKOYFIHH

Please note that separate instructions for the payment of Appeal Fees exist. These are explained in the relevant section of the Board of Appeal on ECHA's webpage.

In the payment instruction, the invoice number should be indicated as the reference number. According to Article 17(1) of the REACH Fee Regulation (EU) No340/2008, in its latest version (see QA 716), every payment must indicate the invoice number. Thus, in the free text message/communications field of the payment you should indicate only the payment reference indicated on the invoice. It is comprised of eight digits and you will find it next to ECHA's bank details on the invoice. This is very important, as your payment is automatically processed by REACH-IT. Please instruct your accounts payable/payments department and your bank accordingly.

What are the consequences of not paying an invoice within the extended payment due date?

Where the payment of a fee is not made by the extended payment due date or by the extension of the second deadline, the submission will be rejected or deemed not to be received. In the above mentioned cases, a rejection due to non-payment is not related to the status of the technical completeness check (TCC). Your submission will be rejected regardless of a given prolonged deadline to fulfil information requirements by submitting further information. Furthermore, if your submission is rejected, the REACH Fee Regulation (EU) No340/2008, in its latest version (see QA 716), stipulates that the fees paid in relation to that submission before its rejection shall not be refunded or otherwise credited to you. After you have received the rejection letter, you are able to start your submission process from the beginning.

Why is ECHA's invoice without value added tax (VAT)?

ECHA does not carry out an economic activity within the meaning of Directive 2006/112/EC on the common system of value added tax. This means that no VAT has to be paid on the fees defined in Regulation (EC) No 340/2008 ('the REACH Fee Regulation'). For the reason above, ECHA has no VAT number and ECHA's invoices are exempt from VAT. ECHA's Finnish Business ID number is 2139942-8 and it is always mentioned on ECHA's invoices. However, this number is not a VAT number.

Why are the activities of ECHA not taxable?
It is important to note that ECHA is not a private company or a service provider but a European public authority established by Regulation (EC) No 1907/2006 ('the REACH Regulation') which is directly applicable in all Member States. Article 102 of REACH provides that the Protocol of Privileges and Immunities of the European Communities shall apply to the Agency. This Protocol is part of the EU Treaties also directly applicable in all Member States, and according to the Protocol, the Agency is exempt from all taxes.
 
The exclusion of ECHA activities and transactions from taxation also results from Article 13(1) of Directive 2006/112/EC (2 on a common system of value added tax, which stipulates:
 
"States, regional and local government authorities and other bodies governed by public law shall not be regarded as taxable persons in respect of the activities or transactions in which they engage as public authorities, even where they collect dues, fees, contributions or payments in connection with those activities or transactions".
 
As it is not a taxable person, ECHA does not have a tax residence in any Member State and thus has no taxation number in Finland.
 
The invoices that ECHA sends to companies relate to fees for PPORD notification, registration and other submissions that ECHA collects pursuant to Regulation (EC) No 1907/2006 ('the REACH Regulation') and Commission Regulation (EC) No 340/2008 ("the REACH Fee Regulation"). Thus, they do not concern private transactions but are fees under public law applicable in all Member States. Based on Directive 2006/112/EC and particularly Article 13(1), these fees are not subject to taxation in any Member State. In the absence of taxation of the fees in any Member State or elsewhere, ECHA shall not be bound to complete any formalities imposed on taxable persons for the avoidance of double taxation.
 

Thus it is important to note that ECHA is unable to provide registrants a VAT or a withholding tax / tax at source residence certificate. As ECHA has no tax residence in any Member State. In QA 739 ECHA has published a financial identification form confirming its Finnish business ID.

1) OJ C 310, 16.12.2004, p. 261
2) OJ L 347, 11.12.2006, p. 1
How long does it take until ECHA receives my payment?

Since 1 November 2009, a SEPA payment must be transmitted within three banking business days. The bank statement of any given day is available to ECHA only on the next banking business day. Therefore, it normally takes up to five banking business days before ECHA can handle your payment and confirm the invoice as paid in REACH-IT. Please note that the handling time may be longer if your payment cannot be dealt with automatically. By following ECHA's instructions regarding payments you can significantly reduce ECHA's handling time of your payments (see QA 721).

How does ECHA handle my payment?

On the basis of the daily electronic bank statement, REACH-IT automatically matches your payment with your open invoice if you have indicated the correct payment reference (invoice) number in your payment message and you have paid the correct amount. An additional condition is that you pay each invoice separately as a single payment. One bank transaction per invoice therefore ensures the fast registration of your payment.

ECHA strongly advises you not to pay two or more invoices in the same transaction ("multiple invoice payment"). If you however include more than one invoice in the payment, please make sure that the invoice references are mentioned in full. Otherwise, the payment has to be manually handled by ECHA's accounting department. This may delay the processing of the payment and thus also the overall completeness check of your registration. If, for some reason, you cannot avoid sending multiple invoice payments and you are unable to indicate the full reference numbers in the payment, please make sure to follow the instructions in QA 732, which describes the sending of payment advices.

How can I help ECHA to swiftly deal with my payment ensuring a successful registration?
Your payment can be swiftly dealt with by ECHA if the guidelines below are followed when making your bank transfer:
  1. Pay one invoice per transaction (single payment);
  2. Indicate the correct reference number (eight digit invoice number);
  3. Ensure the invoiced amount is paid in full (no charges or exchange rate differences);
  4. Instruct your bank to send a SEPA payment with shared cost.
If you discover a mistake after your payment has been made, please immediately contact ECHA via the ECHA Helpdesk web form available at http://echa.europa.eu/contact.
 
How should I react to an invoice reminder?
ECHA sends you one invoice reminder for an unpaid invoice. The reminder contains an extended due date. The invoice reminder is automatically sent by the REACH-IT system one day after the initial due date. (see QA719).
If you receive a reminder but you have already paid the invoice, you can ignore the reminder.
If you have not yet paid when you receive the reminder, please make sure that you respect the extended due date as your REACH submission will otherwise be rejected.
Please note that there are separate instructions for appeal fees.
 
How can I see that ECHA has received and validated my payment?

ECHA does not send confirmations of receipt of payment, but you can check the status of your payment in REACH-IT. Open the submission report and look at the “Submission processing steps” section; the "Financial completeness check" step will be green when your payment has been received and accepted by ECHA.

Please note that it may take several days before ECHA receives the payment depending on the payment method. A SEPA payment is transmitted within three bank business days.

A submission is subject to both a technical and a financial completeness check. Therefore, a fully paid invoice does not necessarily indicate an accepted submission of your REACH dossier.

When should I provide ECHA with a payment advice?
A payment advice can either be an extract from your accounts payable department attached to your email message in PDF format or simply a list of the invoice numbers paid, their total amount and the payment date in the email message itself.
 
A payment advice must be sent in the following cases:
- your payment reference (invoice) number was incorrect;
- in the case of a multiple invoice payment where each invoice number is not mentioned in the bank payment message;
- by request of ECHA's accounting department.
 
If you have indicated the reference (invoice) number in your payment message and it is correct, ECHA does not need any separate payment advice.
 
A payment advice should be sent to the email address of ECHA's accounting department which is: payments@echa.europa.eu.
Please indicate 'Payment advice and the payment date' in the subject field. Example: "Payment advice 19 March 2016".
 
No payment advice by conventional mail is required unless ECHA exceptionally requests it.
What is a proof of payment and when does it need to be sent to ECHA?
The proof of payment can either be a copy of your bank statement or a separate confirmation stamped by your bank.
 
The bank statement can serve as proof that you paid ECHA's invoice by the extended due date. The bank statement copy or the document stamped by your bank must clearly show the date when you ordered the bank transfer.
 
If ECHA has received your proof of payment but has not received the payment within a time period judged normal for bank transfers, ECHA's accounting department will contact you.
 
Please observe that a payment advice printed from your accounting programme is not a valid proof of payment. A proof of payment needs to be issued or officially certified by your bank.
 
Proofs of payment should be sent as scanned PDF attachments to the email address of ECHA's accounting department: payments@echa.europa.eu.
 
No proofs of payment by conventional mail are required unless ECHA exceptionally requests them.
 
Does ECHA send credit notes?

When an invoice is cancelled (e.g. due to incorrect information on the invoice, such as billing information, company size, etc.), you will receive a credit note for the whole amount and, if needed, a replacement invoice. These electronic documents can be downloaded from your REACH-IT account in PDF format. If you receive two invoices and one credit note, the reference number you should indicate in your bank transfer is the reference number of the latest invoice.

If you pay an invoice for which ECHA later issues a credit note, the paid amount will be credited back to your company by either reallocating the received amount to another open invoice or refunding the amount to you.

Please be informed that ECHA doesn't provide any credit notes in case the invoice was not paid in full and your registration was rejected.

What are the rules for a refund?
In certain cases of double payment or overpayment, ECHA will refund the received amount paid in excess. Moreover, fees or charges paid after the rejection of the submission are refunded as undue payments.
 
For the payment of refunds, ECHA will request the bank account information of your company. In addition, ECHA requires your company to complete and sign the following two forms in order to process the refund:
 
"Legal entities" which can be found at:
and "Financial identification" that can be found at:
 
You can choose your preferred language. Please also read the privacy statement.
 
However, please note that fees or charges paid in relation to a submission before its rejection cannot be reimbursed or otherwise credited pursuant to Articles 3(7), 4(7), 5(7), 7(5), of the Fee Regulation and Article 20(2) of the REACH Regulation (Regulation (EC) No 1907/2006).
 
For more details on the rules and procedure, please refer to ECHA Decision ED/61/2008 on refund of fees and charges pursuant to Article 10(4) and 20(1) of the Commission Implementing Regulation (EU) No 254/2013 of 20 March 2013 amending Regulation (EC) No 340/2008. The Decision on refund of fees and charges is available at: http://echa.europa.eu/documents/10162/13559/ed_61_refund_fees_charges_en.pdf
Do ECHA invoices have to be electronically signed?
After your submission has been received by ECHA, you will receive your invoice electronically via REACH-IT – no paper invoice is sent. Invoices can be downloaded in PDF format from your REACH-IT account.
 
The requirements mentioned in Directive 1999/93/EC on electronic signatures do not apply to invoices issued by ECHA. The rule on electronic signature of invoices is based on Article 233 of Directive 2006/112/EC ('the VAT Directive'), which according to Article 220, only applies to taxable persons. However, ECHA is not a taxable person, but an EU public body that does not carry out any economic activity.
 
In any case, the purpose of the provisions of the VAT Directive relating to electronic invoices is to guarantee the authenticity of the origin and the integrity of the content. For invoices notified by ECHA, this objective is met in a more efficient way. Invoices issued by ECHA are notified to their recipient through REACH-IT, which is a secured online platform through which only ECHA can notify information to individual registrants in confidence.
How can I prepare my accounts payable department or my accounting company in view of ECHA's invoices?
In order to ensure the timely payment of ECHA's invoices we recommend the following:
 
All the information you need for proceeding with the payment is visible in the invoice itself. However, depending on your internal administrative procedures, it is advisable that your accounting/accounts payable department is prepared for the payment of ECHA's invoices.
 
We therefore recommend that you set up ECHA's bank account information in the accounting system well in advance of the first invoice's due date. The following link contains ECHA's financial identification form with all the needed details: http://echa.europa.eu/documents/10162/13611/echa_financial_identification_sheet_en.pdf
 
If you use an external accounting company, please ensure that all required information about ECHA and REACH is passed on, in order to ensure the smooth handling of ECHA's invoices. It is also advisable that you ensure beforehand that there are no misunderstandings related to ECHA's status as an EU body which is exempt from any national tax or any value added tax. Please refer to QA 725 and 726.
 
Please make sure that the persons handling the payments of ECHA's invoices are aware that the payment should be made at the full amount so that any possible bank charges are not deducted from the payment.
 
Please inform your accounting department that if the invoice is paid after the extended due date, the REACH dossier submission will be rejected and the paid fee will not be refunded.
 

Please ensure that ECHA’s invoice number is stated in the payment instruction (see QA 721).

What information about my company appears on ECHA's invoice and credit note?
The following information about your company will be visible on the invoices, invoice reminders and credit notes:
 
  • Company name and billing address indicated by the registrant (the information filled in the tab "Billing company information" in REACH-IT is the one that will appear on the invoice);
  • Customer ID number (= Legal entity UUID);
  • DUNS number and VAT number (if provided by the registrant during the sign-up, can be modified later on in the company information section);
  • Purchase order number (if provided by the registrant when submitting the dossier or when accepting a legal entity change).
Before submitting the dossier, please make sure that all the above mentioned information is correctly indicated in your REACH-IT account if you require it to be visible on ECHA's invoice.
Does ECHA need a purchase order for my submission?
When submitting a dossier or accepting a legal entity change, you are able to indicate your own internal purchase order number. It is not possible to add any forgotten purchase order number or modify it afterwards.
 
As you register online in REACH-IT you should not send any purchase orders by ordinary mail or email to ECHA. Please make sure that your system does not send any purchase orders automatically to ECHA. Your purchase order is only for your internal purposes. ECHA will not confirm your internal purchase order or provide information to or access third party platforms for handling your purchase orders.
 
What is the contact address of ECHA's accounting department (accounts receivable)?

For any enquiry, please contact ECHA by using the ECHA Helpdesk web form that is available at http://echa.europa.eu/contact.

My company information has changed and the invoice is not correct; does ECHA issue updated invoices?

If your invoice has not been paid yet, ECHA will be able to cancel it and create a new one with your updated company information. If the invoice has already been paid, ECHA is not in a position to modify the invoice.

ECHA is unable to update any company information in REACH-IT. It is the responsibility of the REACH-IT account owner within the company to make sure that the information is up-to-date.

Firstly, please update your company information in REACH-IT as soon as possible. You can easily update your information in Menu >> Manage Company >> Company information. Here you can modify and update your information by clicking on "Update" at the top right corner of the page. Always remember to save your changes. Additional information on how to update your company information can be found in the ECHA Accounts Manual for Industry Users

After the company details have been updated, you need to contact the ECHA Helpdesk by using the web form available on the ECHA website.

Company size information

If the changes in your company information are related to a change in the company size or to an incorrectly declared company size, please refer to the SMEs section on the ECHA website.

Who is entitled to a fee waiver?

You are entitled to the fee waiver if:

  1. Your substance is a phase-in substance and considered to be low risk (i.e. does not meet the Annex III criteria of REACH); and
  2. You submit a standard registration dossier for 1-10 tonnes per year voluntarily providing the full set of information listed in Annex VII.

The fee waiver does not apply if:

  • Your substance is considered to be low risk (i.e. does not meet the Annex III criteria) and you submit a registration dossier for 1-10 tonnes per year with only physicochemical information (listed in section 7 of Annex VII); or
  • Your substance is not considered to be low risk (i.e. meets the Annex III criteria) and therefore, you must provide the full Annex VII information; or
  • Your substance is a non-phase-in substance.
The above is based on Articles 12(1)(a) and 74 of REACH, taking into account Recital 34 of the regulation.

Important notes
In a joint submission, the tonnage band of the other member registrants does not influence the applicability of the fee waiver for your own dossier.

You need to actively claim the fee waiver in IUCLID to benefit from it – the system does not grant it automatically.

More information on the Annex III criteria and their applicability can be found here.

 

How can I add a Purchase order to my Invoice?

If you want to link a purchase order to an invoice, you should specify this in the third step of your dossier creation wizard (see screenshot). ECHA will not accept any request for a purchase order to be included to an already issued invoice. ECHA does not provide information to, nor does access third party platforms for handling purchase orders.

invoice of purchase order

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